IN THE CIRCUIT COURT OF THE 15' JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN. CASE NO. 502009CA040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS. individually and L.M., individually, Defendant(s). INITIAL MEMORANDUM IN OPPOSITION TO DISOUALIFICATION COMES NOW Fred Haddad. as co-counsel for Jeffrey Epstein, and files his Initial Memorandum in Opposition to Disqualification and would state as follows: The Court will hear further testimony and obviously argument on Edwards' Motion to Disqualify on November 26. The undersigned will present a short memorandum at this time in support of opposition to Edwards' Motion. In his Response in opposition to the Motion, the undersigned observed what basically, save the testimony of Edwards, still holds true "[T]he present Motion to Disqualify the undersigned contains no affidavits, no citation to applicable Florida Bar Rule, nor any case law . . ." hence the undersigned is still in essence replying in the blind. Since that October 1 filing Edwards still has not graced the Court nor the opposition with any authority for his postulations. Coral Reef of Key Biscayne Developers. Inc. V. Lloyds. 911 So.2d 155 (Fla. 3rd DCA 2005). was a situation where the trial court disqualified counsel as that Court determined the "petitioner's counsel acquired useful information and an unfair tactical advantage from privileged documents afforded by a court order, which was subsequent]) quashed by this court" [the Third District Court of Appeals]. The District Court. however, then quashed the order of disqualification. The Appellate Court began its opinion decisio t with the following observation: Florida courts have consistently held that disqualification of a party's chosen counsel is an extraordinary remedy. See Whitener v. First Union Nat'l Bank of Fla. 901 So. 2d 366 (Fla. 5th DCA 2005); Page I of 14 EFTA00593403